Forfaiting structures

A finance structure sometimes used to reduce the cost of finance for PPPs is the forfaiting model, which can be used for 'government-paysPPP projects. Under this model, once construction is completed satisfactorily, the government issues an irrevocable commitment to pay the project company a portion of the contract costs-typically sufficient to cover debt service. This can lower the project's financing costs. However, it means the government retains more risk under the PPP, and as debt service payments are no longer conditional on performance, the lender has less interest in ensuring project performance during operations. The forfaiting model has been widely used in Germany for small projects-typically municipal projects-where over half of the PPPs implemented between 2002 and 2006 used this structure. For more detail on the forfaiting model, see Daube's article comparing project finance to the forfaiting model [#57].

A variant of the forfaiting model is the cession de créance (assignment of receivables) used in France. Similarly, once the infrastructure is built and operational the government may commit to making a series of payments unconditional on availability that will cover some or all of the debt service of the PPP project company.

The Government of Peru has also introduced a financing structure for PPPs that is a variant on the forfaiting model, in which these irrevocable payment commitments are issued during construction on completion of defined milestones. The 'CRPAO' structure is described in Box 1.11: CRPAOs in Peru. These forfaiting-type models allow for the private partner to gradually finance its investment, by securitizing the guaranteed future flow of payments related to each phase of construction. However, it also means the Government is committed to paying a proportion of the contracted amount irrespective of whether the asset is completed. The relevance of this approach may depend on the nature of the asset-in particular, whether it is readily divisible.

Box 1.11: CRPAOs in Peru

In Peru, an innovative financing structure has been developed to finance construction of its road concessions. The Government of Peru issues PAOs (Pago Annual de Obras or 'annual payments for work') to the private contractor for completing construction milestones. PAOs are obligation of the Government of Peru to make dollar-denominated payments on an annual basis (similar to bonds). After they are issued, the payments are not linked to the performance or operation of the roads and are irrevocable and unconditional. Debt for the project is raised through bonds that are backed by the securitization of the PAOs, known as CRPAOs (Certificado de Reconocimiento de Pago Annual de Obras).

Peru first used this financing structure in 2006 to finance the first 960km piece of the IIRSA Interoceania Sur. The project raised US$226 million in debt for the project with a US$60 million partial credit guarantee from the Inter-American Development Bank (IADB). Two subsequent pieces of the Interoceania Sur have also used the CRPAO financing structure.

Source: Fox, Kabance & Izquierdo (2006) IIRSA Norte Finance Limited, New York: Fitch Ratings; United States Agency for International Development, USAID (2009) Enabling Sub-Sovereign Bond Issuances: Primer and diagnostic checklist (FS Series 1), Washington, D.C.